The city is located in the extreme southwest corner of the state. It lies on
the northwest side of the Chetco River, which enters the Pacific Ocean at the city's
western border. The unincorporated community of Harbor lies directly across the river
from the city. The city's current comprehensive plan, which LCDC acknowledged on
January 27, 1983, established a UGB that includes the Brookings city limits, the
community of Harbor, and a number of additional areas on the edges of those
boundaries. That UGB presently contains over 9,000 residents. The Brookings area is
expected to grow to over 16,000 people within the next 20 years.

In part because of the anticipated growth, the Department of Land
Conservation and Development (DLCD) notified the city in mid-1992 to begin the
periodic review process. In late July 1993, DLCD approved the city's periodic review
program (work program), which identified a number of specific tasks (work tasks) and
gave priorities and target dates for each. The numbered work tasks are: (1) to amend the
UGB, among other things in order to provide a 20 year supply of vacant buildable land
(priority A); (2) to establish an urban reserve boundary (priority B); (3) to amend the
comprehensive plan and land use ordinances to deal with a number of issues, including
the extension of the UGB resulting from work task 1 (priority C); (4) to adopt a public
facilities plan for the new UGB, including providing for extending public services to the
newly included areas (priority D); and (5) to develop a transportation system plan
(priority D). Each work task had a separate target date for completion. The later tasks
depended in part on the earlier ones; for instance, the city was not to begin work on
numbers 4 and 5 until it had completed number 1.

In its preliminary work on work task 1, the city concluded that, in order to
accommodate the anticipated population growth and other needs, it had to add 899 acres
of buildable land to the existing UGB. The city found some difficulty in locating the
needed land because of the geographical character of the Brookings area, which is a
narrow flatland between rugged hills on the east and the ocean on the west. Much of the
urbanizable flat land was already inside the existing UGB. The city was able to find part
of the needed additional land by expanding the UGB to include existing exception areas
and a limited amount of resource land on the relatively flat areas north of the city. That
additional land, however, was not sufficient to meet the city's need.

The city decided that the best location for additional vacant buildable acres
was in the Harbor Hills. It therefore included a large portion of those hills, beginning
directly east of the Harbor Bench agricultural lands and continuing over the top of the
hills and down the other side, in the expanded UGB. It recognized that, because of their
topography, the western slopes of that portion are not buildable. However, the city found
that other sections of the area contain a significant amount of land that is buildable at a
variety of price levels. It justified including the unbuildable land in the UGB on the
grounds that that land was necessary in order to provide urban services to the buildable
land and that excluding it would create a confusing boundary, with non-UGB land
surrounding UGB land in an illogical pattern.

Petitioners' arguments are, in one way or another, attacks on the inclusion
of the Harbor Hills area in the UGB. Because many of those arguments are based on
LCDC's alleged failures to consider issues related to goals other than Goal 14, the
urbanization goal, we first consider the nature of the issues before LCDC on its review of
this specific periodic review work task. Although we have previously considered land
use issues that arose in the context of a periodic review, with the one exception that we
mention below we have not discussed the process involved or how the stages of that
process affect DLCD's and LCDC's review of local government action or our review of
LCDC's decisions.

The purpose of periodic review is to ensure that acknowledged
comprehensive plans and land use regulations continue to achieve the statewide planning
goals. Periodic review is appropriate when there has been a substantial change in
circumstances so that the plan and regulations no longer comply with the goals, when
implementation decisions lead to results inconsistent with the goals, or when there are
regional or statewide issues that must be addressed in order to bring the plans and
regulations into compliance with the goals. ORS 197.628. In short, the foundation of
periodic review is that the previously acknowledged plan and regulations no longer
qualify for acknowledgment, either on their face or as applied.

Periodic review has two major phases; each consists of a number of more
minor steps. It is a process, not an event that occurs at a single time. The first phase is
the evaluation of the existing plan and its implementation and the development of a work
plan to make needed changes in the plan and regulations. The work plan consists of a
number of work tasks for the local government to perform over a designated period of
time. Each work task, in turn, has a number of specific parts. The second phase is the
completion of the work tasks outlined in the work plan. ORS 197.633(1). The first
phase is complete when the local government adopts the work plan and DLCD approves
it, subject to appeal to LCDC. ORS 197.633(3).

Because work plans consist of a number of work tasks, and because the
later tasks often depend on the completion of the earlier tasks, the second phase of
periodic review is a sequential process. Work tasks are subject to DLCD review and
acknowledgment as they are completed, but the periodic review as a whole is not
acknowledged until DLCD, and LCDC if there are any appeals, have reviewed and
acknowledged all of the work tasks. As the statutes and rules recognize, the sequential
nature of a work program means that work on a later work task may have an impact on a
previously completed work task, even after its initial acknowledgment. Thus, LCDC
may modify the approved work program when, among other things, issues of goal
compliance are raised as a result of the completion of a work task that results in a need to
undertake further review or revisions. ORS 197.644(1)(b). When a later work task
conflicts with a work task that has been deemed acknowledged, or when a later work task
violates a goal related to a previous work task, DLCD and LCDC will not approve the
submission until all conflicts and goal compliance issues are resolved. OAR 660-25-140(5).

The periodic review process, thus, is designed to be sequential and
interactive, with later decisions potentially requiring a reworking of previous decisions or
previously acknowledged work tasks. The revised comprehensive plan and land use
regulations must comply with all of the goals at the conclusion of the process, when they
become effective. During the process, however, it may well be appropriate for a
particular work task to focus on a limited number of goals. In this case, for instance, it
would be difficult to comply with work task 4, requiring the preparation of a public
facilities plan, a task that implicates Goal 11, until the completion of work task 1, the
expansion of the UGB, a task that primarily implicates Goal 14.

Only one of our opinions touches on the periodic review process as a
process. In that opinion, we assumed that a decision on a later work task could require
the reevaluation and revision of a previously-completed work task. In Callison v. LCDC,
145 Or 277, 929 P2d 1061 (1996), rev den 325 Or 403 (1997), one petitioner argued that
the City of Portland's adoption of Goal 5 natural resource plans had the effect of reducing
the city's buildable homes inventory and thus violated Goals 10 and 14. We noted that
the city had not yet completed the work task of amending its residential buildable lands
inventory. We agreed with LCDC and the city that it was most appropriate to consider
the Goal 10 and 14 issues in conjunction with that work task. "If ensuring compliance
with those or other goals affects the natural resource plans at issue in this case, the city
[of Portland] will have to make appropriate adjustments to those plans * * *." Because
of the sequential and interactive nature of the periodic review process that we described
in Callison, many of petitioners' arguments in this case are premature.

The nature of the periodic review process also affects the applicability of
some of the LUBA and Court of Appeals opinions on which petitioners rely. The issue
in those cases was the validity of an amendment to an acknowledged comprehensive
plan. See, e.g. 1000 Friends of Oregon v. City of North Plans, 27 Or LUBA 372, aff'd
130 Or App 406, 882 P2d 1130 (1994). Unlike the periodic review process, plan
amendments involve specific and limited changes to existing plans that are otherwise in
compliance with the goals. An amendment is complete when approved and must,
therefore, meet all requirements at that time. However, in a periodic review that is as
thorough as this one, it is impossible for a general revision and expansion of the UGB
fully to satisfy all requirements at this stage of the process in the same way that a
specific, limited amendment to an existing and otherwise unevaluated UGB must.

In conducting a periodic review, the planning agency does not make one
specific change in isolation; rather, it reevaluates the entire situation in order to bring the
plan and land use regulations back into compliance with the goals. That process is much
closer to the original development and acknowledgment of the plan and regulations than
to a plan amendment. At the end of the periodic review process, the entire plan and
regulations, including the UGB, must fully comply with all requirements. At this stage
of the Brookings process, however, we can determine only whether the UGB complies to
the extent that it is possible for it to do so in light of the unknown results of the
remaining work tasks.

In their various "assignments of error,"(3) petitioners argue that LCDC's
qualified acknowledgment of the city's expanded UGB violated a number of the goals.
We first consider their argument that it violated Goal 14, the urbanization goal, which
describes seven factors to consider in establishing and modifying a UGB:

Petitioners first argue that the expanded UGB violates factors 1 and 2 of
Goal 14, the "need" factors, because it includes far more land than the city identified as
necessary to provide for its probable growth in the next 20 years. Instead of the 771
acres that, according to petitioners, the city needs, it adopted a UGB that includes an
additional 3,491 acres. Petitioners argue that it would be possible to find the needed
acres entirely north of the Chetco River without including any part of the Harbor Hills.
For that point they focus on two exception areas north of the city. They also attack
LCDC's conclusion that it was necessary to add a large amount of unbuildable land in the
Harbor Hills in order to reach and serve the buildable land in that area. They concede
that that

"argument would be legitimate if the City was compelled to include the
Harbor Hills in order to meet its land needs of 771 acres - in order to reach
the flatter, buildable portion of the Harbor Hills at the top of the Hills,
urban services such as sewer and water lines would arguably have to be
built across the large, unbuildable portion of the Harbor Hills." (Emphasis
in original.)

By conceding that the city's argument would be legitimate if the city had to
include the Harbor Hills to meet its need for buildable land, petitioners necessarily
concede that the Goal 14 need factors would be satisfied in that event. That concession
resolves this argument because, as respondents point out, petitioners misunderstand the
record. The city in fact needs an additional 899 buildable acres, not 771, and the areas
that petitioners identify north of the Chetco River are inadequate to satisfy that need.
LCDC could also find that the excluded exception areas do not contain the amount of
buildable land that petitioners suggest. For those reasons, it was necessary for the city to
look to the area south of the river, which as a practical matter means the Harbor Hills. In
light of those facts and in light of this concession, petitioners have not shown that LCDC
erred on this ground in approving the city's expansion of the UGB in that area.

Petitioners next argue that the city failed to comply with the requirements
for Goal 2 exceptions for the areas that it added to the UGB.(5) Goal 14 requires a change
in a boundary separating urbanizable from rural lands to meet the requirements of the
exceptions process of Goal 2.(6) There is no assertion that the Harbor Hills area satisfied
the first, physically developed, or the second, irrevocably committed, ground for an
exception. Petitioners recognize that satisfying the Goal 14 factors is sufficient to satisfy
the first and fourth parts of the third, standards, ground.(7) Our discussion of the problems
with petitioners' proposed alternative land north of the Chetco River shows that it met the
second and third, "alternatives," part of this ground. The expanded UGB, therefore,
qualifies for a Goal 2 exception, and we therefore reject petitioners' arguments based on
the exceptions criteria of that goal.

We hold, thus, that LCDC did not err in approving the city's expanded
UGB at this stage of the periodic review process. We express no opinion on whether
actions that the city, DLCD, and LCDC may take at later stages of that process will
require any reevaluation of that issue.

Affirmed.

1. LCDC has exclusive jurisdiction to review completed work program tasks.
ORS 197.644(2). Action pursuant to that authority is a final order subject to our review
under ORS 197.650. ORS 197.644(4)(a).

3. An assignment of error is an assertion that the court or agency made an
erroneous ruling or took an erroneous action. See ORAP 5.45 and Appendix H (giving
examples). The only LCDC action that petitioners attack is its qualified
acknowledgment of the city's expanded UGB. In each of their "assignments of error"
petitioners assert that that action violated a goal or part of a goal. Petitioners present
only one true assignment of error: that LCDC erred in approving the expanded UGB.
The various other "assignments" that they assert are in fact different arguments in
support of that single assignment.

4. For similar reasons, LCDC did not err when it concluded that at this time
the city satisfied factors 5, 6, and 7 of Goal 14 when it adopted the expanded UGB. We
also reject petitioners' arguments based on Goal 2, Part I, Goal 10, and Goal 11.

5. Goal 2 provides criteria and a process that permit planning for specific
areas in ways that would violate one or more of the other goals. The result of the Goal 2
process is an exception to that other goal or goals. For example, an area that should
otherwise not be urbanizable may be so built on or surrounded by urban uses that it is
impractical to retain it in agricultural or forest use.

"(1) Reasons justify why the state policy embodied in the applicable
goals should not apply;

"(2) Areas which do not require a new exception cannot reasonably
accommodate the use;

"(3) The long-term environmental, economic, social and energy
consequences resulting from the use of the proposed site with measures
designed to reduce adverse impacts are not significantly more adverse than
would typically result from the same proposal being located in areas
requiring a goal exception other than the proposed site; and

"(4) The proposed uses are compatible with other adjacent uses or
will be so rendered through measures designed to reduce adverse impacts."